Can You Read Me Now?

The Consumer Financial Protection Bureau (CFPB) is currently in the process of updating Regulation P ... that's the federal rule requiring American financial institutions to snail mail a privacy notice to you at least once each year.

This is good news for financial institutions in that under the updated rule, banks will likely be able to stop direct mailing the annual notice to you, but instead they'll be allowed to post it on a website for you to view electronically using your computer. Think of the savings in paper, printing, stuffing, and postage! Life is good for bankers!

And life looks good for you, too because soon you'll be able to view any bank's privacy notice on the big, fat screen of your desktop or laptop computer. View it when you want it ... ignore it until you need it.

Just one little detail is troubling. Earlier this week, a CFPB presentation contained the following statement:

"One study by the Federal Reserve found that one-third of cell phone users and more than half of smartphone owners are using mobile banking services. And according to one independent researcher, approximately 74,000 consumers per day began using mobile banking services last year."

As we see and acknowledge this trend towards doing our banking business on mobile devices, here's the troubling detail:  The proposed Regulation P update provides no information or guidance relating to how privacy notices will be delivered on the diminutive screens of smartphones, tablets, and phablets.

As the new Reg P rule is finalized, it's our hope and expectation that the rulemakers will recognize this as an opportunity to leverage technology to bring readable, understandable, timely privacy information to each and every banking customer.